Low/No tax company structure in Europe

It needs to be in Europe ?
Are you EU resident ?

The best structure for this is:

Hungarian Kft - Cyprus Non domiciled company + Panama foundation

You will be invoicing to your clients from Hungarina KFt. Your hungarian KfT will be invoice by Cyprus Non domiciled company. All profits will be paid to Panamian foundation as dividends.

There are a few steps which need to be done. In right order. Success is in details.

Why this structure?

1. There is no withholding tax in Hyngary.
2. Hungary and Cyprus are in EU
3. Cyprus has not cash transactions limits

onemansomewhere said:

The best structure for this is:

Hungarian Kft - Cyprus Non domiciled company + Panama foundation

You will be invoicing to your clients from Hungarina KFt. Your hungarian KfT will be invoice by Cyprus Non domiciled company. All profits will be paid to Panamian foundation as dividends.

There are a few steps which need to be done. In right order. Success is in details.

Why this structure?

1. There is no withholding tax in Hyngary.
2. Hungary and Cyprus are in EU
3. Cyprus has not cash transactions limits

Sounds really interesting @onemansomewhere ! Can I ask 3 questions?

1) Do you have to worry about being 'found out' under the control of company rules, and having to pay income tax in your home (EU) country with a set-up like this?

2) How hard (in terms of ID checks needed, and also costs to set-up) is this to get set-up?

3) How to cash-out in the EU? Can the Panama foundation issue something like a debit card?

Sorry for all the questions, just has me intrigued.

1. Depends on your country of residency or country of citizenship. In some countries yes and in some countries no. There is a way to go around by obtaining a residence permit in more reasonable country..

2. Depends on wour willingness to travel, your knowledge of law, type of business, etc.. not so easy to say..

3. You withdraw money from cypriot bank account and you have money in cash, then you make a resolution of dividends payment to a foundation. And you make a cash payment receipt.. Cyprus and Panama does not have any cash transactions limits.

onemansomewhere said:

1. Depends on your country of residency or country of citizenship. In some countries yes and in some countries no. There is a way to go around by obtaining a residence permit in more reasonable country..

2. Depends on wour willingness to travel, your knowledge of law, type of business, etc.. not so easy to say..

3. You withdraw money from cypriot bank account and you have money in cash, then you make a resolution of dividends payment to a foundation. And you make a cash payment receipt.. Cyprus and Panama does not have any cash transactions limits.

Thanks for the info!

onemansomewhere said:

Hungarian Kft - Cyprus Non domiciled company + Panama foundation

I imagine you would need substance / permanent establishment in both locations for this to work? I'm aware that original poster is banned, just curious about the details of this arrangement

WOW, those are a whole lot of moving parts for no reason. If you are trying to launder millions of euro than yes, maybe but if you are conducting business (small to middle level company) you simply need to set up a tax friendly set up. Form a company in a tax friendly jurisdiction (no corporate taxes due as long as you are not generating revenue from that particular country), open an EMI account if easier than a traditional retail account so you can take advantage of local tax laws and there you go. If you are trying to launder millions of euro that is a different conversation. ;)

GAC Limited said:

(no corporate taxes due as long as you are not generating revenue from that particular country)

No offence but where are you getting this information from?
You're saying you only need to pay corporate tax unless revenue is flowing in from the incorporation company?

In a nut shell, if company A is incorporated in a tax friendly jurisdiction where they are taxed only on revenue generated from the incorporating country. Hence, company A is taxed at Zero corp tax rate for revenues generated outside of the country of incorporation. Only taxes to be paid would be on the income from the individuals salary/profit disbursement of their home country. The information is common knowledge for professionals in the financial arena. This is what I do for a living fyi. But, great question and thanks.

GAC Limited said:

In a nut shell, if company A is incorporated in a tax friendly jurisdiction where they are taxed only on revenue generated from the incorporating country. Hence, company A is taxed at Zero corp tax rate for revenues generated outside of the country of incorporation. Only taxes to be paid would be on the income from the individuals salary/profit disbursement of their home country. The information is common knowledge for professionals in the financial arena. This is what I do for a living fyi. But, great question and thanks.

Any example countries where this works?